ANTI SLAVERY AND HUMAN TRAFFICKING POLICY

ANTI SLAVERY AND HUMAN TRAFFICKING POLICY

POLICY STATEMENT

Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as: slavery, servitude, forced and compulsory labour and human trafficking. All of which have in common the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain. We have a zero tolerance approach to modern slavery and we are committed to acting ethically and with integrity in all our business dealings and relationships, and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our own business or in any of our supply chains.

Gleeds:

• Supports and respects the protection of internationally proclaimed human rights.

• Respects the rights of workers to join, form or not to join worker organisations including trade unions.

• Does not use forced or compulsory labour. Employment is voluntary.

• Complies with local minimum age laws and does not employ child labour.

• Provides employees with a safe and healthy workplace.• Prohibits corruption in all its forms, including extortion

and bribery.• Believes that freedom of expression is a fundamental

human right.• Requires all employees and supply chain partners to

adhere to these principles and to all other Gleeds policies, practices and procedures.

Gleeds is also committed to:

• Making certain that it is not complicit in human rights abuses.• Promoting environmental responsibility and encouraging

the development and application of environmentally friendly technologies.

• Maintaining workplaces that are free from discrimination or harassment based on race, colour, religion, creed, gender (including pregnancy), sexual orientation, marital status, gender identity, national origin and ancestry, genetics, citizenship status when otherwise legally able to work, age, disability, veteran status, or any other characteristic protected by applicable law.

We are also committed to ensuring there is transparency in our own business and in our approach to tackling modern slavery throughout our supply chains, consistent with our disclosure obligations under the Modern Slavery Act 2015. We expect the same high standards from all of our contractors, suppliers and other business partners. As part of our contracting processes, we include specific prohibitions against the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude, whether adults or children, and we expect that our suppliers will hold their own suppliers to the same high standards.

This policy applies to all persons working for us or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives and business partners.

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RESPONSIBILITY FOR THE POLICY

The HR Board has overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under our control comply with it.

The Chair of the HR Board has primary and day-to-day responsibility for implementing this policy, monitoring its use and effectiveness, dealing with any queries about it, and auditing internal control systems and procedures to ensure they are effective in countering modern slavery.

Management at all levels are responsible for ensuring those reporting to them understand and comply with this policy, and are given adequate and regular training on it and the issue of modern slavery in supply chains.

COMPLIANCE WITH THE POLICY

You must ensure that you read, understand and comply with this policy.

The prevention, detection and reporting of modern slavery in any part of our business or supply chains is the responsibility of all those working for us or under our control. You are required to avoid any activity that might lead to, or suggest, a breach of this policy.

You must notify your manager as soon as possible if you believe or suspect that a conflict with this policy has occurred, or may occur in the future. You are encouraged to raise concerns about any issue or suspicion of modern slavery in any parts of our business or supply chains of any supplier tier at the earliest possible stage.

If you believe or suspect a breach of this policy has occurred or that it may occur you must notify your manager or report it in accordance with our Whistleblowing Policy as soon as possible.

If you are unsure about whether a particular act, the treatment of workers more generally, or their working conditions within any tier of our supply chains constitutes any of the various forms of modern slavery, raise it with your manager.

We aim to encourage openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken. We are committed to ensuring no one suffers any detrimental treatment as a result of reporting in good faith their suspicion that modern slavery of whatever form is or may be taking place in any part of our own business or in any of our supply chains. Detrimental treatment includes dismissal, disciplinary action, threats or other unfavourable treatment connected with raising a concern. If you believe that you have suffered any such treatment, you should inform the HR Partner immediately. If the matter is not remedied, and you are an employee, you should raise it formally using our Grievance Procedure.

COMMUNICATION AND AWARENESS OF THIS POLICY

Training on this policy, and on the risk our business faces from modern slavery in its supply chains, forms part of the induction process for all individuals who work for us, and regular training will be provided as necessary.

Our zero tolerance approach to modern slavery must be communicated to all suppliers, contractors and business partners at the outset of our business relationship with them and reinforced as appropriate thereafter.

BREACHES OF THIS POLICY

Any employee who breaches this policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct.

We may terminate our relationship with other individuals and organisations working on our behalf if they breach this policy.

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January 2017

ANTI SLAVERY AND HUMAN TRAFFICKING POLICY